Two Major Stakeholders Seek Financial Institutions’ Exclusion under FATCA Reporting Rules

Two major stakeholders asked the Internal Revenue Service to exclude a wide range of financial institutions from the broad new reporting, disclosure, and withholding requirements in the Foreign Account Tax Compliance Act (FATCA) in…

Large Canadian Bank Seeks Disclosure Exception for Some Foreign Accounts under FATCA

A major Canadian bank Aug. 11 asked the Internal Revenue Service not to require the disclosure of accounts in foreign jurisdictions that already send detailed tax information to the United States, as the…

Carried Interest Tax Increase, S Corporation Curbs Softened in New Tax Extenders Proposal by Senate Finance Panel Chair Baucus

Senate Finance Committee Chairman Max Baucus (D-Mont.) June 16 introduced a new substitute amendment (S. Amdt. 4369) to the tax extenders bill (H.R. 4213) that would…

Newly Codified Economic Substance Doctrine Could Mean More IRS Challenges, Practitioners Say

The newly codified economic substance doctrine may clear the way for Internal Revenue Service challenges to a broader range of transactions than before, tax practitioners said May 20…

Practitioners Disappointed by Supreme Court’s Rejection of Petition to Review Textron Ruling involving Work Product Protection

Attorneys concerned about the work product protection issues raised in the Textron Inc. v. United States ruling by the U.S. Court of Appeals for the First Circuit told BNA they are…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

Developed Country Banks, Offshore Financial Centers Holding Illicit Funds, Group Says

Banks in more than a dozen developed countries absorbed from 46 percent to 67 percent of “illicit financial flows” from developing countries from 2002 to 2006, while at least 10 offshore financial centers absorbed…

Leeway Urged for Some Foreign Payments under Generator Rules

Loss sharing or joint tax settlements permitted under foreign law should not automatically result in foreign payments being considered “noncompulsory” under rules to crack down on deals to…

IRS, Treasury Working on Consolidated Groups Guidance Under Net Operating Loss Carryback

The Internal Revenue Service and Treasury Department soon will issue guidance to address issues for consolidated groups raised by the recently enacted five-year net operating loss carryback…

Economic Substance Changes Would Have Biggest Impact on Firms in Three Circuits

Taxpayers operating in the regions covered by the Courts of Appeal of the Second, Fourth, and Eighth Circuits will be most affected by the health care law’s changes to the way the economic substance doctrine is applied to…

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